Landowner Moutonshoek Investments legal submission on Draft EMP

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(i)
Supplementing the Objectors’ <strong>submission</strong>s submitted to WEC on or about
30 April 2010; and
(ii)
Providing comments on the draft EMP compiled by the Applicant.
7. It is also submitted that this <strong>submission</strong> should be read in conjunction with all other
<strong>submission</strong>s, comments and objections submitted by other landowners in the
Prospecting Area, Interested and Affected Parties and the Verlorenvlei Coalition
representing in excess of 1500 members.
HISTORY
8. It is the Objectors’ <strong>submission</strong> that before dealing with the application and the EMP the
events preceding this application should be recorded.
9. Although the Applicant and WEC wish to downplay the history and would argue that
this application is a “new” application and should be considered afresh, it is the
Objectors’ <strong>submission</strong> that this application can not be seen in isolation, but should be
dealt with, with due cognisance of two previous prospecting right applications and two
previous unsuccessful mining right applications submitted by the Applicant in respect
of the same properties to which this application relates.
10. These applications were as follows:
(i)
A prospecting right application submitted by the Applicant during
September 2005. This application was rejected on grounds of pollution
concerns;
(ii)
The second prospecting right application submitted by the Applicant on or
about September 2006. This application was granted on 3 April 2007 but
was taken on judicial review by the objectors. The right lapsed before the
review could be finalised;
(iii)
The first mining right application WC 30/5/1/2/2/328 MR submitted by the
Applicant on 25 March 2009. After vigorous objections clearly indicating
deficiences in the application and related documentation and the apparent
LITTLE SWIFT INVESTMENTS // NAMAQUASFONTEIN BOERDERY TRUST: OBJECTION AGAINST PRA WC434